WHAT ACTION DOES THE SEPTEMBER 25 NOTICE IMPLEMENT?
On September 25, 2025, the Federal Register will publish a notice from the Department of Commerce’s International Trade Administration (ITA) and the Office of the United States Trade Representative (USTR) implementing tariff modifications under the U.S.-EU Framework on Reciprocal, Fair, and Balanced Trade. Although the notice is scheduled for formal publication tomorrow, the effective dates for these tariff changes are already in place.
Building on the authority granted by Executive Order 14346, the amendments to the Harmonized Tariff Schedule of the United States (HTSUS) establish specific tariff reductions and exemptions for automobiles, aircraft, natural resources, and pharmaceuticals.
HOW ARE AUTOMOBILE TARIFFS CHANGING FOR IMPORTERS?
Effective for entries on or after August 1, 2025, new tariff provisions apply to automobiles and automobile parts under Proclamation 10908.
The framework establishes differentiated treatment based on the most-favored nation (MFN) rate:
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Passenger vehicles and light trucks with an MFN duty of more than 15 percent are filed under new subheading 9903.94.50, with no reciprocal tariff applied.
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Passenger vehicles and light trucks with an MFN duty of less than 15 percent are filed under new subheading 9903.94.51, paying a combined 15 percent rate (MFN plus reciprocal duty).
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Automobile parts follow the same structure under new subheadings 9903.94.52 and 9903.94.53
WHICH PRODUCTS ARE EXEMPT FROM RECIPROCAL TARIFFS?
Beginning September 1, 2025, broad exemptions take effect under new HTSUS provisions:
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Natural resources: Subheading 9903.02.74 exempts over 200 tariff lines covering goods such as cork, ores, industrial minerals, and other resources classified in Chapters 7, 8, 9, 25, 26, 28, 31, 32, 36, 38, 45, 50, 71, 72, 79, 80, and 81.
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Essential oils: Subheading 9903.02.75 exempts “essential oils other than those of citrus fruit, other, nesoi, for religious purposes only” (3301.29.51).
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Civil aircraft and parts: Subheading 9903.02.76 exempts imports under more than 550 tariff lines spanning Chapters 39, 40, 48, 68, 70, 73, 74, 76, 81, 83, 84, 85, 88, 90, 91, 94, 96, and 98.
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Pharmaceutical products: Subheading 9903.02.77 exempts EU pharmaceuticals across 779 tariff lines in the HTSUS
HOW WILL THESE ADJUSTMENTS BE ADMINISTERED?
ITA and the USTR will administer the HTSUS amendments. U.S. Customs and Border Protection (CBP) will apply the revised tariff provisions at the border, ensuring proper enforcement based on accurate product classification and scope notes provided in the annexes. Commerce and USTR retain authority to adjust the exemption lists in response to changing trade or security conditions.
WHAT IS THE SIGNIFICANCE FOR U.S. IMPORTERS?
For U.S. importers, the framework delivers measurable tariff relief and clarity:
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Automotive importers gain predictable treatment under new subheadings but must carefully validate MFN rates to ensure proper filing.
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Aerospace and MRO operators benefit from duty-free treatment of civil aircraft parts and related equipment, supporting cost reduction in maintenance and manufacturing supply networks.
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Pharmaceutical distributors gain relief under more than 700 tariff lines, provided the products meet the classification and scope limitations.
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Industrial users of natural resources such as cork, ores, and specialty minerals receive tariff exemptions that can lower input costs.
Importers are strongly advised to update compliance systems, train trade teams on the new HTSUS subheadings, and review Commerce and USTR annexes to capture eligible benefits.
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